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Guernsey Regulations to Implement Pillar 2 GloBE Rules

18 December 2024

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Approved Changes

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Guernsey

The Government of Guernsey has published the Income Tax (Approved International Agreements) (Implementation) (OECD Pillar II) Regulations 2024, which were made by the Policy and Resource Committee on 26 November 2024. The regulations provide for the implementation of the Pillar 2 GloBE Model Rules for in-scope MNE groups with consolidated group revenue of EUR 750 million or more in at least two of the four immediately preceding fiscal years. This includes: A Qualified Domestic Minimum Top-up Tax, referred to as the Guernsey Domestic Top-up Tax (DTT); and A Qualified Income Inclusion Rule (IIR), referred to as the Guernsey Multinational Top-up...